What's the effect of company domination on certification election?

What it settled law, dating from the case of Standard Cigarette Workers' Union v. Court of Industrial Relations, decided in 1957, is that if it were a labor organization objecting to the participation in a certification election of a company-dominated union, as a result of which a complaint for an unfair labor practice case against the employer was filed, the status of the latter union must be first cleared in such a proceeding before such voting could take place. (G.R. No. L-32853; September 25, 1981)

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